Before the Federal Communications Commission Washington, D.C. 20554

In the Matter of Inquiry Concerning Deployment of Advanced Telecommunications Capability to All Americans in a Reasonable And Timely Fashion, and Possible Steps to Accelerate Such Deployment Pursuant To Section 706 of the Telecommunications Act of 1996

Notice of Inquiry
Comments of the Rehabilitation Engineering Research Center on Telecommunications Access at the Trace Center, University of Wisconsin and Gallaudet University

Docket No.98-146

Comments of Trace/Gallaudet

The Trace Center of the University of Wisconsin-Madison and Gallaudet University's Technology Assessment Program have extensive experience in engineering, research, consultation and guideline development regarding accessibility of technology to people with disabilities. The two groups collaborate on a Rehabilitation Engineering Research Center on Telecommunications Access, funded by the National Institute on Disability and Rehabilitation Research (NIDRR).

The opinions expressed here represent those of the authors and not those of the host institutions or funding agencies.

Introduction

We appreciate the opportunity to comment on broadband-related accessibility issues that face people with disabilities, and that affect the equitable delivery of broadband services to all Americans.

Broadband services offer unique advantages to people with disabilities, including elderly people who have become disabled. By giving the potential for new multi-media services, new functions can be gained.

For example, people who have a great deal of difficulty with traveling from place to place can bring the world to their doorsteps for information, shopping, and even medical help. Family members and other caregivers can more easily "look in" on elderly relatives whose condition is frail. The expanded choices of modality for communication offer new communication opportunities to people who may have an impairment affecting the use of one or more modalities.

Among their many benefits, broadband services provide a platform that will support sign language telecommunications. This is a long-awaited development in the deaf community, because the current practice of typing for conversation is not the functional equivalent of voice conversation. Once broadband is universally available and services are interoperable, people who are deaf and use sign language will for the first time have access to natural communication that is the counterpart to voice - able to communicate quickly, laugh together, interrupt when needed. If the network is incomplete and not interoperable, this dream will again be delayed. Delays and uneven implementation will create a have and have-not situation with regard to video relay interpreting services, now authorized for reimbursement under the TRS rules.

In short, equitable delivery of broadband services is of unique value to many people with disabilities and therefore accessibility to and availability of services are particularly important.

Specific access issues regarding broadband are just beginning to emerge as the services are rolled out and people have an opportunity to examine them.

Interface

The interface to the broadband service may be to some extent determined by the broadband provider. For example, if the service is provided through a corporate interface, such as a webpage, then that webpage or other interface of course must be fully accessible or the delivery of services will not be equitable. As many of the services make use of visual interfaces, this merits close attention and further study. Will people who are blind have access to the service? More broadly, can the access features in broadband applications be easily found and turned on and off from the user interface?

Essential to synchronous interpersonal communication is the ability to signal to another person that "I'm calling you." Today one can just hook up a flashing ring indicator to a phone line to be alerted to incoming calls. Unless the phone provides a visual ring indicator and/or a signal that could used to control one, there is no way for the deaf person to know that a call is coming in. This cannot be done when the device is, for example, a computer on a digital network. Broadband services need to be constructed so that they can activate visual or vibrating signaling for people who cannot hear rings and message announcements. The signaling needs to be provided, not just on the device screen as text and/or graphics, but in a vibrating form for wireless devices and a flashing or other effective visual form outside the device, comparable to a flashing ring signal used in telephones. Currently products do not include software that could be developed to activate an external flasher or other signaler. As time passes and new digital communication technologies are rolled out, this is becoming a more and more serious problem. A related issue is message signaling: if unique signals are used to distinguish various messages from live calls, this should also be addressed in visual or vibrating signal implementations.

Text Chat

Broadband services that carry voice traffic need to be compatible with the analog telephone network, and this compatibility needs to include text telephone (TTY) compatibility so that customers who need to communicate with others who have TTY do not need to have separate analog subscriptions just for this purpose. (We have commented extensively on this issue under the NOI on IP telephony, part of the Report and Order on Section 255.) Standards for this purpose have been partially developed but these need to be completed and, above all, implemented.

The introduction of broadband technologies into residences and places of employment provides a way for deaf, hard of hearing, and speech-disabled people who use text for conversation, to migrate out of the old analog technology (TTY), which has a number of limitations. TTY has been a reliable method of text communication, but it requires specialized customer premises equipment, it is slow, and users cannot interrupt each other in conversation. When more people and businesses have access to a broadband pipeline that is always available, the current population of TTY users will have more opportunities to have direct text chat with people who do not have TTYs. This trend, already evidenced through the use of such products as AIM and ICQ for text chat between people with and without disabilities, should continue to reduce reliance on telecommunications relay services. The use of text chat would be greatly enhanced by the widespread implementation of ITU Recommendation T.140, a plain text chat protocol, in all digital communications products. T.140 has been designed by the industry to be easy to implement, and if present would provide a way in which people communicating in digital environments. Industry should take steps to implement industry standards such as T.140, designed to improve accessibility.

Videotelephony

The issues surrounding videotelephony for sign communication and video relay interpreting are complex, and merit further investigation by the Commission.

A great deal of progress has been made in specifying requirements for sign language support in the International Telecommunications Union. The ITU-T's H Series Supplement 1 gives guidance on video quality requirements for signing and lipreading. For comfortable signing, at least 25 frames per second and good quality (CIF) resolution should be supported (although sign communication can be done, by slowing the pace of signing, as low as 15 frames per second). But as more people avail themselves of broadband services, there will be competition for bandwidth. The best technologies available for coding and transmitting sign language, at the lowest possible rates, should be deployed as widely as possible in order to support signed conversations.

Some of the potential problem areas in broadband deployment include the use of relatively low data rates for the outgoing data stream. This is presumably based on evidence that people need to receive at high data rates (e.g., for streaming video) far more than they send; but for sign language communication, low outbound data rates will restrict the quality of the transmission. Thus, people may not be able to use video relay interpreting even though they have purchased what promises to be broadband service.

Another problem is delay. Processing images takes time, and there is some delay between sending and receiving a video image; but conversation is sensitive to delay, which disrupts turntaking. Conversational uses of broadband therefore require rapid transmission. The ITU's limit for usability in conversation is 400 milliseconds, but passage through multiple nodes, plus time required for encoding and decoding at the ends can make the delay far longer than this upper limit.

Using the Internet as the transport between terminals or between networks has some advantages, but the amount of bandwidth available often fluctuates on a call. Attention to quality of service issues for video/signing should be added to the efforts underway for improving quality of service in IP telephony. Some form of bandwidth protection for sign language calls would improve continuity and clarity on a call.

Even where bandwidth is dedicated, as on ISDN service, the technology is still not mature. Gallaudet participated as a site in a video relay interpreting trial last year. The largest technical problems, and the hardest for the end-user to detect and diagnose, occurred in the network, where switching among providers and queuing ISDN calls at the interpreting site were insufficiently robust to support a reliable service.

As mentioned above, the question of ring-signaling has not been solved in digital environments. This is becoming an ever-important issue, since digital text and video communication offer such important benefits - but they cannot be treated as "calls" in the conventional sense because deaf and hard of hearing people do not have a functionally equivalent way of being alerted to a digital call.

Captioning and Video Description

SMIL, a standard for off-line captioning of web video, has been approved by the Worldwide Web Consortium. The MPEG-4 standard has provisions for captioning. As with other industry standards, implementation is the key to accessibility. Some companies have provided captioning utilities for their video products and the Web. Needed are new methods and standards for captioning in real-time streaming video, and for building into all products separate audio channels that can be used for live description of video. Products need to be able to accommodate third-party service providers - companies that perform the real-time captioning and the description, and thus standards are very important. We invite the industry to provide, in reply comments, information on plans for supporting these real-time services in a standardized way, so that third party providers of these services may offer them on broadband networks.

Wireless Broadband

As Chairman Kennard stated at the recent Wireless 2000 conference, "Wire-less is more." We expect wireless devices to become important mechanisms for multi-media service delivery, and therefore it is vital that these products will be accessible.

The NOI asks "What different or additional factors distinguish delivery of such broadband applications by wireline and wireless technologies?" One important aspect is that the visual interface will become increasingly important, and it is not clear how people who are blind will attain access to broadband visual services in wireless devices. Screen access is of course a huge problem in wireline services as well, but the addition of software for screen reading is better supported in a computer, whereas within a personal digital assistant or other wireless device, support for screen access is much less certain. It will be important that the operating systems of such devices support accessibility features that have been developed over the years and that are available in, for example, in PC-based Windows versions but not in Windows CE. The current FCC guidelines would address this - but only if telecommunication over IP and other digital networks is defined as telecommunication for accessibility reasons and the FCC guidelines therefore apply.

With regard to text chatting, compatibility between wireless telephones and the current text telephones (TTYs) has been ordered by the FCC. The first TTY-compatible wireless phones are expected to be seen in 2001.

Many companies in the wireless industry are showing evidence of commitment to implementation of Section 255, a promising trend for future accessibility. We have been informed that the 3GPP has decided to standardize text telephony and text conversation in third-generation systems. This is doubtless a result of the FCC's Order that wireless technology be accessible via text telephones.

However, beyond the area of text telephony, it is not clear that the standards groups working on future generations of wireless communications are thinking about and building in accessibility into those services' infrastructures. Will signing be supported in the plans for wireless video? Will ring signaling be available in all devices? We look forward to the results of this inquiry to learn from industry if these issues are indeed being addressed.

Future technologies

It is also important that mechanisms be in place to ensure that accessibility continues to be considered as new technologies are introduced. These mechanisms will ensure that companies that do address accessibility are not at an unfair disadvantage (an un-level playing field) because other companies are free to ignore access regulations. Even large companies can now be put at risk by smaller companies if they do not all have to follow the same rules. The current pressure to ignore access rules on telephony that occurs over IP does not bode well for industry carrying the access forward to new technologies as they emerge. The FCC has issued a good set of guidelines on Section 255; the guidelines need to apply to emerging technologies.

Respectfully Submitted,

Gallaudet Technology Assessment Program
Judith E. Harkins, Ph.D.
Gallaudet University
Technology Assessment Program
800 Florida Avenue, NE
Washington, DC 20002
202-651-5257 (V/TTY)
judy.harkins@gallaudet.edu

Gregg C Vanderheiden Ph.D.
Trace R & D Center
University of Wisconsin Madison
2107 Engineering Centers Bldg.
1550 Engineering Dr.
Madison WI 53706
608/263-5788
gv@trace.wisc.edu

This document is hosted on the Trace R&D Center Web site. Please visit our home page for the latest information about Designing a More Usable World - for All.

Notice of Inquiry Comments of the Rehabilitation Engineering Research Center on Telecommunications Access at the Trace Center, University of Wisconsin and Gallaudet University

Comments of Trace/Gallaudet

Introduction

Future technologies

Notice of Inquiry
Comments of the Rehabilitation Engineering Research Center on Telecommunications Access at the Trace Center, University of Wisconsin and Gallaudet University